Current Project

The Interaction of Different Tax Systems in the Taxation of Cross-border Services

In its Workstream II, the Intergovernmental Negotiating Committee on the UN Framework Convention on International Tax Cooperation is debating possible options for the reform of cross-border taxation.

This research explores how the tax systems of countries that are major exporters of digitally provided services (United States, United Kingdom, Singapore, India, China, Ireland, France, Japan, Germany, Swizerland, United Arab Emirates, the Netherlands, South Africa) deal with taxes imposed by importing countries on these services. It investigates specifically under what conditions double taxation relief is available under their domestic laws.

This is conducted mainly through desk research and complemented by interviews and/or surveys with tax practitioners and tax directors of companies working in these jurisdictions, to take into account their perspective on the practicalities of obtaining double taxation relief in their home jurisdictions for taxes imposed by jurisdictions to which services are exported.

The research is carried out together with the International Bureau for Fiscal Documentation (IBFD), a research institute based in the Netherlands working on international taxation.

Researchers

Frederik Heitmüller

Frederik Heitmüller is an Associate Postdoctoral Fellow with ICTD’s International Tax Team. His research focuses on policies against corporate tax avoidance, the influence of international norms in the Global South and global tax governance. He is also an independent consultant on tax policy. Prior to joining ICTD, he obtained a PhD from Leiden University, Netherlands, where he investigated the political economy of the BEPS Project in the Global South as member of the GLOBTAXGOV project, and taught courses on international and comparative taxation. He has a master’s degree in political science from Sciences Po Bordeaux and University of Stuttgart.

Florian Dierich

Florian Dierich is a consultant currently working as an Associate Research Officer with the International Tax Team at ICTD. His work focuses on international tax cooperation. Previously, Florian has worked on international tax frameworks, including the OECD’s Two-Pillar Solution, the Global Solidarity Levies Task Force and EU tax policies. He holds a Research Master’s in Political Science from Sciences Po Paris.

Martin Hearson

Martin Hearson is a Research Fellow at IDS, Research Director of the ICTD and the International Tax programme lead. His research focuses on the politics of international business taxation, and in particular the relationship between developed and developing countries. Before joining ICTD, Martin was a fellow in international political economy at the London School of Economics and Political Science, teaching courses on political economy and global financial governance.
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